Cleanup, Clearance Testing, Waste Disposal and Recordkeeping
Final cleaning
Work top-down and from the farthest corner toward the exit: HEPA vacuum ceilings, walls, sills and floors, wet wash with detergent, rinse, then HEPA vacuum again. Change rinse water and cleaning pads often. After final cleaning, wait at least one hour before wipe sampling so airborne dust settles, and keep the area restricted until clearance passes.
Clearance
Clearance is visual plus dust sampling. Visual means no dust, debris, paint chips or residue on floors, sills, ledges or troughs. Then a certified inspector, risk assessor or sampling technician who did not perform the abatement collects wipe samples from floors, interior sills and window troughs and compares results to clearance levels (currently 5, 40 and 100 µg/ft²). A failure means reclean and resample; the job is not finished until clearance passes.
Waste and wastewater
Bag or drum debris in sealed, labeled containers; never burn, bury or leave it on site. Determine whether the waste is RCRA hazardous by TCLP testing; if it is, manifest it. Never discharge lead-bearing wash water to a storm drain; settle or filter it and dispose per local pretreatment rules.
Records
Deliver the abatement report to the owner within 10 working days of completion and retain records for three years: dates, address, supervisor and firm names, testing results, work practices, clearance data and waste disposition. OSHA exposure and medical records are kept 30 years.
Traps
- Treating a clean visual as clearance.
- Letting the abatement crew perform its own clearance.
- Sampling immediately after cleaning, before dust settles.
- Assuming all paint debris is RCRA hazardous - or that none of it is.
Rule of thumb
One hour, then sample; three years for the project file, thirty for exposure records.